From Pillar 2 to post: is it time for a change in concentration risk methodology?

Chris Leaney

The Herfindahl-Hirschman Index (HHI) is a measure of diversification, commonly used as an indicator to calculate banks’ credit concentration risk capital requirements (where credit concentration risk is potential losses from undiversified portfolios). According to BCBS (2019) HHI is employed by c. 50% of regulators, including the Prudential Regulation Authority (PRA) since 2016. However, despite some evidence that the data-light, easy-to-implement HHI produces broadly comparable outcomes with formal models (eg Bundesbank (2006)), such evidence is limited to large banks or theoretical datasets. In this post I examine the relationship between HHI and a formal model of sector and geographical concentration risk. I show that, for a wide sample of bank sizes, HHI is poorly correlated with the model outputs for both risk types.

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